Cross-Border Tax Glossary: India, UAE and USA Terms

A

Accredited Service Provider (ASP)

A provider accredited by the UAE Ministry of Finance to exchange e-invoices and report tax data to the Federal Tax Authority. UAE businesses must appoint one under the e-invoicing mandate. UAE e-invoicing →

Advance Pricing Agreement (APA)

An agreement between a taxpayer and the tax authority, sometimes with a foreign authority too, that fixes the transfer pricing method or price for future years. In India it now sits in sections 168 and 169 of the Income-tax Act, 2025. Section map →

Annual Performance Report (APR)

The yearly report an Indian investor files through its bank on each overseas direct investment, due by 31 December, covering the foreign entity’s financial performance. FEMA filings →

Arm’s length principle

The rule that prices between related parties must match what independent parties would agree in comparable circumstances. Both India and the UAE apply it to all related-party transactions, whatever their size. India-UAE transfer pricing →

Article 17 (artistes and sportsmen)

The tax treaty article that lets the country where an entertainer or sportsperson performs tax the income from that performance, even without a permanent establishment. Article 17 explained →

B

Beneficial owner

The person who actually owns and controls income such as dividends, interest or royalties, as opposed to an intermediary or conduit. Reduced treaty rates on these payments are usually available only to the beneficial owner. Treaty documentation →

C

Connected person (UAE)

For UAE corporate tax, an owner, director or officer of a business, or a related party of any of them. Payments to connected persons are deductible only at market value. UAE transfer pricing thresholds →

D

Deemed resident

An Indian citizen whose Indian income, other than foreign-source income, exceeds Rs 15 lakh and who is not liable to tax in any country by residence or domicile. A deemed resident is always RNOR. NRI residential status →

Delaware flip

Restructuring an Indian company so that a new US holding company, usually in Delaware, owns it, typically to raise money from US investors. The Delaware flip →

DMTT (Domestic Minimum Top-up Tax)

The UAE’s 15% minimum tax on large multinational groups, with consolidated revenue of EUR 750 million or more, from 1 January 2025, under the OECD Pillar Two rules. UAE corporate tax explained →

DTAA

Double Taxation Avoidance Agreement: a tax treaty between two countries that allocates taxing rights and caps withholding rates. In India, treaty relief is given under section 159 of the Income-tax Act, 2025. India-UAE DTAA rates →

E

Effectively connected income (ECI)

Income of a non-resident that is connected with a trade or business in the United States. It is taxed in the US; income without that connection usually is not. US LLC for Indian residents →

F

FC-GPR

The FEMA form an Indian company files through its bank to report shares issued to a foreign investor, due within 30 days of allotment. FEMA late fees →

Form 128

The application for a certificate of lower or nil deduction of tax under section 395 of the Income-tax Act, 2025. It replaced Form 13 from 1 April 2026. Form 128 guide →

Form 145 and Form 146

The remitter’s declaration (Form 145) and the accountant’s certificate (Form 146) for payments to non-residents under section 397(3)(d). They replaced Form 15CA and Form 15CB. Form 145 and 146 →

Form 42

The information a non-resident furnishes to claim tax treaty benefit in India where its tax residency certificate lacks prescribed particulars. It replaced Form 10F. Form 42 and the TRC →

Form 48

The accountant’s transfer pricing report under section 172 of the Income-tax Act, 2025, which replaced Form 3CEB for transactions from 1 April 2026. Section map →

Form 5472

The US information return a foreign-owned single-member LLC files each year with a pro forma Form 1120 to report transactions with its owner. The penalty for not filing is USD 25,000. Form 5472 guide →

G

GAAR

The General Anti-Avoidance Rule, which lets the Indian tax authority disregard an arrangement whose main purpose is a tax benefit. It applies where the tax benefit exceeds Rs 3 crore and was retained unchanged in the 2025 Act. Section map →

GILTI and NCTI

US rules that tax US shareholders on certain income of their foreign subsidiaries each year. GILTI was renamed net CFC tested income (NCTI) with changes from 2026. GILTI becomes NCTI →

L

Late Submission Fee (LSF)

The fee that regularises a delayed FEMA filing: Rs 7,500 plus 0.025% of the amount involved for each year of delay, or a flat Rs 7,500 for returns without a flow of funds. LSF calculator →

Liberalised Remittance Scheme (LRS)

The Reserve Bank’s scheme allowing a resident individual to remit up to USD 250,000 a financial year for permitted purposes, including overseas investment. ODI vs LRS →

Local file and master file

Transfer pricing documentation. The master file describes the group; the local file analyses the local entity’s controlled transactions. In the UAE both are required from AED 200 million of revenue or AED 3.15 billion of group revenue. UAE thresholds →

N

Non-Resident (NR)

For Indian tax, a person who is not resident in the tax year under section 6. A non-resident is taxed only on income received in India or accruing or deemed to accrue in India. NRI residential status →

O

Overseas Direct Investment (ODI)

Investment by a person resident in India in the unlisted equity of a foreign entity, or 10% or more of a listed one, or with control. It is governed by the Overseas Investment Rules, 2022. ODI vs LRS →

Overseas Portfolio Investment (OPI)

Investment by a person resident in India in foreign securities that is not ODI, such as less than 10% of a listed foreign company without control. US LLC for Indian residents →

P

Permanent establishment (PE)

A fixed place of business, or certain agents or services, through which a foreign enterprise carries on business in a country. Under a treaty, business profits are taxable in the other country only if there is a PE there. Section 393 →

POEM (place of effective management)

The place where key management and commercial decisions for a company’s business as a whole are in substance made. A foreign company with its POEM in India is resident in India for tax. POEM risk →

Q

Qualifying Free Zone Person (QFZP)

A UAE free-zone entity that meets the conditions for the 0% corporate tax rate on qualifying income, including adequate substance, audited accounts and transfer pricing compliance. QFZP conditions →

R

Reverse charge

A GST mechanism under which the recipient, not the supplier, pays the tax. Payments to foreign artists for performances in India attract 18% IGST under reverse charge. GST on artist fees →

Reverse flip

Moving the holding company of a group from abroad, often Delaware, back to India, usually ahead of an Indian listing, commonly through an inbound merger. Reverse flip →

RNOR

Resident but Not Ordinarily Resident: a resident who was non-resident in 9 of the previous 10 years, or spent 729 days or less in India in the previous 7 years, or is resident only under the 120-day or deemed residency rules. Foreign income is generally not taxed. Residency checker →

S

Section 393

The provision of the Income-tax Act, 2025 on tax deduction at source. Section 393(2) covers payments to non-residents, replacing section 195 and section 194E. Section 393 explained →

Small Business Relief (SBR)

A UAE corporate tax relief that treats a resident person with revenue of AED 3 million or less as having no taxable income, for tax periods ending on or before 31 December 2026. UAE corporate tax explained →

T

Tax Residency Certificate (TRC)

A certificate from a country’s tax authority confirming that a person is resident there for tax. India requires one before a non-resident can claim a treaty rate. UAE TRC for Indians →

TCS on LRS

Tax collected at source by the bank on remittances under the Liberalised Remittance Scheme, at 20% above Rs 10 lakh a year for most purposes other than education and medical treatment. It is credited against the remitter’s income tax. ODI vs LRS →

Transfer pricing disclosure form (UAE)

A schedule filed with the UAE corporate tax return listing related-party transactions, required when they exceed AED 40 million in the tax period. UAE thresholds →